phdci Privacy Policy

1. Data Controller Information

phdci (referred to in this Privacy Policy as "phdci," "we," "us," or "our") is the data controller responsible for the personal data collected through the phdci online gaming platform accessible at phdci.cam. As data controller, phdci determines the purposes and means by which personal data is processed in connection with the operation of our online casino, sports betting, bingo, slots, and related gaming services offered to players in the Republic of the Philippines.

phdci processes all personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. For matters relating to anti-money laundering compliance, data processing is also conducted in accordance with the Anti-Money Laundering Act (AMLA) and applicable PAGCOR regulations.

2. Scope and Application

This Privacy Policy applies to all personal data collected, used, stored, or otherwise processed by phdci in connection with:

• Your registration and maintenance of a phdci account;
• Your use of any game, service, or feature on the phdci platform;
• All deposit and withdrawal transactions conducted through phdci;
• Your communications with phdci customer support;
• Your participation in phdci promotions, bonuses, or loyalty programs;
• Your browsing activity on the phdci website, including via cookies and similar technologies;
• Any other interaction you have with phdci that involves the provision of personal information.

By creating a phdci account or using our platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register for a phdci account, complete KYC verification, make deposits or withdrawals, or interact with our support team, you provide us with personal data, which may include:

3.2 Data Collected Automatically

When you access and use the phdci platform, we automatically collect certain technical and behavioral data, including:

• Device and Technical Data: IP address, device type, operating system and version, browser type and version, screen resolution, device identifiers;
• Usage and Gameplay Data: Pages visited, games played, bets placed, session duration, click patterns, navigation path through the platform;
• Location Data: General geographic location derived from your IP address (used for jurisdiction verification and fraud prevention);
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 9 of this Policy.

3.3 Data from Third Parties

phdci may receive personal data about you from third-party sources in limited circumstances, including:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) for the purpose of verifying and processing transactions;
• Identity verification service providers engaged to assist with KYC compliance;
• Fraud prevention and anti-money laundering screening services;
• PAGCOR or other regulatory authorities, where required by law.

4. Purposes of Data Collection and Processing

phdci processes your personal data for the following purposes:

• Account Management: To create, maintain, secure, and administer your phdci account;
• Identity Verification (KYC): To verify your identity, confirm you meet the 21-year minimum age requirement, and comply with PAGCOR and AMLA obligations;
• Service Delivery: To provide access to games, process bets, calculate and credit winnings, and deliver all features of the phdci platform;
• Payment Processing: To process deposits and withdrawals, verify payment methods, and maintain transaction records;
• Fraud Prevention and Security: To detect, investigate, and prevent fraud, unauthorized account access, money laundering, and other illegal activities;
• Regulatory Compliance: To fulfill legal obligations under Philippine law, including PAGCOR reporting requirements, AMLA transaction monitoring, and NPC data protection requirements;
• Customer Support: To respond to inquiries, resolve disputes, and deliver assistance through our 24/7 support channels;
• Responsible Gaming: To monitor gameplay patterns, identify at-risk behavior, enforce self-exclusion and limit settings, and promote responsible gaming across the platform;
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the quality and performance of the phdci platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided your consent or where permitted by law. You may opt out at any time.

5. Legal Basis for Processing

phdci processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and phdci — including account management, service delivery, and payment processing — is carried out because it is necessary to fulfill our obligations to you;
• Legal Obligation: Processing required to comply with Philippine laws and PAGCOR/AMLA regulatory obligations, including identity verification, transaction monitoring, and mandatory reporting;
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring carried out on the basis of phdci's legitimate interests, provided these interests do not override your fundamental rights;
• Consent: Processing for marketing communications and certain analytics carried out on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 Service Providers and Processors

phdci shares personal data with trusted third-party service providers who assist us in operating the platform, subject to strict data processing agreements that bind them to confidentiality and security obligations equivalent to those applied by phdci. These providers include:

• Payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank);
• Identity verification and KYC service providers;
• Fraud detection and anti-money laundering screening services;
• Cloud infrastructure and hosting providers;
• Customer support platform providers;
• Game software providers and live dealer studio operators.

6.2 Regulatory and Legal Disclosures

phdci may disclose your personal data to government authorities, regulatory bodies, or law enforcement agencies where required or permitted by Philippine law, including but not limited to: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and courts or tribunals of competent jurisdiction.

6.3 No Sale of Personal Data

phdci does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Any sharing of data with third parties is limited to what is strictly necessary for the operation of the phdci platform and compliance with legal obligations.

7. Data Retention

phdci retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of your account relationship with phdci, plus a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by AMLA and PAGCOR regulations;
• KYC Documentation: Retained for a minimum of five (5) years following the end of the customer relationship;
• Support Communications: Retained for a period of two (2) years from the date of the interaction, unless a longer period is required by law or ongoing dispute resolution;
• Cookie and Analytics Data: Retained for a period not exceeding thirteen (13) months from collection, unless renewed with your consent.

Upon expiry of the applicable retention period, phdci will securely delete or anonymize your personal data in a manner that prevents reconstruction or identification.

8. Data Security

phdci implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and phdci is encrypted using industry-standard 256-bit SSL/TLS encryption. Sensitive data at rest (including financial records and identity documents) is encrypted using AES-256 encryption;
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All staff with access to personal data undergo background screening and regular data privacy training;
• Two-Factor Authentication: Available to all phdci account holders and required for all internal administrative access;
• Intrusion Detection: Continuous network monitoring and intrusion detection systems operate across the phdci infrastructure;
• Regular Audits: phdci undergoes periodic security audits and penetration testing by qualified third-party security professionals;
• Incident Response: phdci maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phdci will notify the National Privacy Commission and affected data subjects within the timeframes prescribed by the Data Privacy Act.

9. Cookies and Tracking Technologies

9.1 Types of Cookies Used

phdci uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the platform, improve your experience, and gather analytics. The categories of cookies used are:

• Strictly Necessary Cookies: Essential for the operation of the platform, including session management, authentication, and security features. These cannot be disabled without impairing platform functionality;
• Functional Cookies: Remember your preferences such as language settings, last-played games, and display options to personalize your experience;
• Analytics Cookies: Collect aggregated, anonymized data on how players use the platform, including pages visited and session duration. Used to improve platform performance and content;
• Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and multiple-account violations.

9.2 Managing Cookies

You may manage or disable non-essential cookies through the cookie preference settings accessible on the phdci platform. Please note that disabling certain cookies may affect the functionality of the platform. Most web browsers also allow you to manage cookie settings directly; refer to your browser's help documentation for instructions.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdci. To exercise any of these rights, please contact our Data Privacy Officer using the contact details in Section 14.

11. Protection of Minors

phdci strictly prohibits the creation of accounts or participation in any real-money gaming activity by individuals under the age of 21 years, consistent with Philippine law and PAGCOR regulations. phdci does not knowingly collect, use, or retain personal data from individuals under 21.

If phdci discovers that personal data has been collected from a person under 21, the relevant account will be immediately closed, all gameplay voided, and the personal data deleted or returned in accordance with applicable law. If you believe that phdci has inadvertently collected data from a person under 21, please notify our Data Privacy Officer immediately at the contact details provided in Section 14.

12. Cross-Border Data Transfers

In the course of providing its services, phdci may transfer your personal data to service providers or infrastructure systems located outside the Republic of the Philippines, including in other jurisdictions where our game providers, cloud hosting, or support systems operate. Where such transfers occur, phdci ensures that:

• The receiving country provides an adequate level of data protection as recognized by the NPC; or
• Appropriate safeguards are in place, such as contractual data protection clauses that impose equivalent obligations on the receiving party; or
• The transfer is necessary for the performance of the contract between you and phdci.

phdci does not transfer personal data internationally in ways that would expose your data to materially lower protections than those provided under Philippine law.

13. Changes to This Privacy Policy

phdci reserves the right to update or modify this Privacy Policy at any time. Any changes will be reflected in an updated "Last Updated" date at the top of this document. Material changes — those that significantly affect how your personal data is used or your rights as a data subject — will be communicated through account notification, email, or prominent notice on the phdci platform.

Your continued use of the phdci platform following any changes to this Privacy Policy constitutes acceptance of the updated policy. We encourage you to review this Privacy Policy periodically. If you disagree with any changes, you may close your account by contacting phdci customer support.

14. Contact and Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by phdci, or if you wish to exercise any of your data subject rights, please contact our Data Privacy Officer through the following channels:

• Data Privacy Officer, phdci
• Email: [email protected]
• Live Chat: Available 24/7 through the phdci platform
• Response Time: phdci will acknowledge data subject rights requests within 72 hours and endeavor to fulfill all requests within 15 calendar days, subject to identity verification and the complexity of the request.

If you are not satisfied with phdci's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC) through their official channels.

This Privacy Policy is issued by phdci and constitutes the complete and governing statement of phdci's data protection practices with respect to the personal data of its players. In the event of any conflict between this Privacy Policy and any other phdci document, this Privacy Policy shall prevail with respect to data protection matters.